Cfatf Annual Report 2017-2018

CARIBBEAN FINANCIAL ACTION TASK FORCE

CFATF ANNUAL REPORT 2017-2018

No reproduction or translation of this publication may be made without prior written permission. Requests for permission to further disseminate reproduce or translate all or part of this publication should be obtained from the CFATF Secretariat at [email protected]

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

TABLE OF CONTENTS CFATF Profile ...... 3 CFATF Mission, Vision and Values ...... 5 Chairman’s Remarks ...... 6 Foreword by the Executive Director ...... 9 Execution of the Chair's Work Programme ...... 10 The CFATF AML/CFT/CVE Workshop for Judges and Prosecutors...... 13 Photos from the Workshop ...... 15

Visit of Chairman Williams to the CFATF Secretariat Office in Port-of-Spain, Trinidad and Tobago ...... 16 Financial Overview ...... 17 Donor support ...... 19 European Development Fund (EDF) ...... 20 10th EDF Accreditation and Training Project ...... 20 11th EDF – EU/CARIFORUM Assists CFATF Implementation of the Mutual Evaluation Programme ...... 21

Year in Pictures ...... 22 Training and Events 2018 ...... 24 Overview of the Mutual Evaluation Programme and the Plenary Process ...... 26 Plenary Meetings ...... 27 CFATF XLVI November 2017 Plenary Highlights ...... 27 CFATF XLVII May 2018 Plenary Highlights ...... 29 CFATF XLVIII November 2018 Plenary Highlights ...... 32

Council of Ministers Meeting ...... 34 Annex 1- The Mutual Evaluation Process (Flowchart) ...... 36 Annex 2 - CFATF Follow-up Process Flowchart ...... 38 Regular Follow-up ...... 38 Enhanced Follow-up ...... 39 FATF ICRG Process Flowchart ...... 40

Annex 3 -Observer Organizations ...... 41 Glossary of terms and acronyms ...... 42

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CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

CFATF Profile

The Caribbean Financial Action Task Force The CFATF Secretariat has been established (CFATF) is an organisation of twenty-five as a mechanism to monitor and encourage (25) states of the Caribbean Basin, Central progress to ensure full implementation of the and South America, which have agreed to Kingston Declaration and has been hosted by implement common countermeasures to the Government of Trinidad and Tobago address money laundering (ML), terrorist since its establishment. The CFATF financing (TF) and proliferation financing Membership includes the following: (PF). It was established as a result of meetings convened in Aruba in May 1990 1. Antigua and Barbuda and Jamaica in November 1992. 2. Anguilla 3. Aruba In Aruba, representatives of Western 4. Bahamas, The Hemisphere countries, in particular from the 5. Barbados Caribbean and Central America, convened to 6. Belize develop a common approach to the 7. Bermuda phenomenon of the laundering of the 8. Cayman Islands proceeds of crime. Nineteen 9. Curacao recommendations constituting this common 10. Dominica approach were formulated. These 11. El Salvador recommendations, which have specific 12. Grenada relevance to the Region, were 13. Guyana complementary to the original forty 14. Republic of Haiti recommendations of the Financial Action 15. Jamaica Task Force (FATF) established by the Group 16. Montserrat of Seven at the 1989 Paris Summit. 17. St. Kitts and Nevis 18. St. Lucia The Jamaica Ministerial Meeting was held in 19. St. Maarten Kingston in November 1992. Ministers 20. St. Vincent and the Grenadines issued the Kingston Declaration in which 21. Suriname they endorsed and affirmed their 22. Turks and Caicos Islands governments’ commitment to implement the 23. Trinidad and Tobago FATF and CFATF Recommendations1, the 24. Venezuela OAS Model Regulations and the 1988 UN 25. Virgin Islands Convention. They also mandated the establishment of the Secretariat to co- The Co-operating and Supporting Nations ordinate the implementation of these (COSUNs) are countries or territories that are objectives by CFATF Member countries. not Members or observers of the CFATF and who have expressed their support for the The main objective of the CFATF is to objectives of the CFATF and have been achieve effective implementation of, and approved by the Council of Ministers. compliance with, the FATF Recommendations to prevent and eliminate COSUNs are committed to the mutual ML/FT/PF. evaluation process for implementing the FATF Recommendations and make contributions to the work and/or resources of

1 The CFATF Recommendations were subsequently retired by the Council of Ministers.

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CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019 the CFATF as are permitted by their • CARICOM/ CARIFORUM respective national laws and policies. • The World Bank (WB) • CARICOM IMPACS COSUN countries include: • The International Monetary Fund (IMF) 1. Canada • The Caribbean Development Bank 2. France (CDB) 3. Mexico • The Commonwealth Secretariat 4. Kingdom of the Netherlands • The Eastern Caribbean Central Bank 5. Spain (ECCB) 6. United Kingdom and • The Inter-American Development 7. The United States of America. Bank (IDB)

• Organization of American States These nations recognise the relationship (OAS) and between the work and objectives of both the FATF and the CFATF. • The United Nations Office on Drugs and Crime (UNODC). The CFATF Secretariat undertakes the following activities on behalf of the CFATF The CFATF Secretariat has Observer Status Membership: with several organisations, a comprehensive list of which is at Annex 3.

• An ongoing programme of the Mutual The CFATF Chair for the November 2017- Evaluation of Members. November 2018 period was held by Guyana • Co-ordination of, and participation in, and represented by the Honourable Basil training and technical assistance Williams, SC, MP, Attorney General and programmes. Minister of Legal Affairs of the Co-operative • Bi-annual plenary meetings for Republic of Guyana. technical representatives.

• Annual Ministerial Meeting. The CFATF Deputy Chair for the November 2017- November 2018 period was held by Additionally, since February 1996, the Barbados and represented by the Honourable CFATF has been conducting a number of ML Adriel Brathwaite, QC, Attorney General of typology exercises in collaboration with the Barbados (November 2017- May 2018) and FATF and other FATF Style Regional Bodies the Honourable Dale Marshall Q.C., M.P., (FSRBs) with a view to increasing awareness Attorney General and Minister of Legal of the attendant risks to the Region. These Affairs of Barbados (May 2018 - November exercises allow for the sharing of information 2018). collated by various bodies involved in combating ML/TF. The Executive Director (ED) of the CFATF for the period is Ms. Dawne Spicer. The CFATF Secretariat also works closely with many international organisations and For more information, please visit our entities, some of which include: website at: https://www.cfatf-gafic.org/

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CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

CFATF Mission, Vision and Values

MISSION

To develop and implement effective anti-money laundering, counter-terrorist financing and counter- proliferation of weapons of mass destruction financing systems and to contribute to the setting of global standards.

VISION

To be an efficient and responsive organisation that plays a leading role, within the region and the global community, in the prevention and suppression of money laundering, terrorism financing and financing the proliferation of weapons of mass destruction through the effective implementation of the international standards.

VALUES

• Leadership

• Effectiveness

• Integrity

• Cohesiveness

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Chairman’s Remarks

Chairman Basil Williams SC, MP, Hon. Attorney General and Minister of Legal Affairs of the Co-operative Republic of Guyana (Guyana)

It is my pleasure to introduce the Annual of the CFATF, forging strong relationships Report of the CFATF for the period with our stakeholders and boosting our public November 2017 - November 2018 under the profile. Chairmanship of Guyana. In November 2017, as incoming Chairman, It has been an honour and privilege to one of my primary tasks was to preside over represent the CFATF during this critical time the CFATF’s XLVI’s Plenary and Working of transition in improving our counter- Groups Meetings hosted by Guyana. At that terrorism measures to match the legislative meeting, we welcomed approximately one and other positive strides achieved within the hundred and fifty (150) participants from our realm of money laundering. Coupled with the twenty-five (25) Member jurisdictions, challenges of the Fourth Round of Mutual COSUNs and Observer organisations, Evaluations, the economies of our small with the dialogue centered around discussion Member States continue to grapple with low of the Mutual Evaluation Report of Barbados. levels of financial growth, recovery from Other matters of the CFATF were also hurricanes and the threat of de-risking. discussed including the ICRG Procedures for Resources are being stretched as we all use the Fourth Round, outcomes of the Financial our best efforts to legislatively strengthen our Action Task Force (FATF) June and October Anti-Money Laundering/Countering the 2017 Plenaries and the Action Plan of Financing of Terrorism (AML/CFT) Trinidad and Tobago. frameworks, establish measures to deal with PF and implement the AML/CFT laws and During the period of January 22-26, 2018, processes to a level that can be considered as Guyana then hosted the CFATF Assessors’ ‘High’ or ‘Substantial’ levels of training which resulted in thirty-eight (38) effectiveness. new assessors being added to the CFATF pool of Assessors. Over the past year, I engaged in several activities, all aimed at fulfilling the mandate

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On April 19, 2018 ED Spicer and I involved in confiscation matters, the represented the CFATF at the Compliance importance of countering violent extremism Aid Anti-Money Laundering & Financial and taking a positive role as an FSRB in an Crimes Conference 2018 in Miami, Florida FATF initiative. (See page 14 for further where we delivered presentations on the details on the outcomes of this meeting). topics ‘FinTech Effects on the Changing Role of the Compliance Officer’ and ‘the current On August 24, 2018, I led the team in Round of Mutual Evaluations-Regional conducting the High-Level Mission to St. Outlook’. Both presentations were well Maarten. Following this meeting, I stressed received. that the CFATF has made progress in its Mutual Evaluation programme, as only St. In May 2018, Guyana then hosted the Maarten remained in the Third Round, with a AML/CFT/CVE (Anti-Money Laundering/ clear commitment to exiting promptly. Countering the Financing of Terrorism/ Countering Violent Extremism) Workshop Under my tenure as Chairman of the CFATF, for Judges and Prosecutors, which was these important advances were attained and undertaken as part of the global series of my Work Programme was executed with workshops for Judges and Prosecutors tangible success in many areas. I further initiated by the then FATF President, Mr. advocated the work being undertaken by the Santiago Otamendi. This initiative of CFATF by my attendance at the FATF President Otamendi commenced in Plenary meetings. These meetings are September 2017 and concluded in May 2018 ultimately aimed at improving our level of in Busan, Korea. The workshop was funded AML/CFT compliance with the FATF by the Commonwealth Secretariat, the Standards and increasing our levels of Cooperative Republic of Guyana and the effective implementation. My strategic Caribbean Development Bank. The Secretary objectives were aimed at ensuring that the General of the Commonwealth, the Right CFATF could undertake its monitoring Honourable Baroness Patricia Scotland, QC responsibilities in the manner expected of us attended and presented at the Workshop. as guardians of the best interests of each and There were opening speeches by His every CFATF Member. Excellency, the President of the Cooperative Republic of Guyana, Brigadier David Arthur In addition, the review and enhancement of Granger, the Secretary General and myself. the IT functionality of the CFATF Secretariat Forty (40) participants from Member as well as the hiring of new staff and the countries comprising a Chief Justice and proposals for Ministers to enhance fourteen (14) other Puisne Judges, one (1) governance, efficiency and effectiveness are Chief Magistrate and twenty-four (24) all in keeping with the CFATF Strategy. Our Prosecutors, including: Directors of Public strategy which has been executed through the Prosecution, Deputy and Assistant Directors Chairman’s Work Programme set a solid of Public Prosecution, Senior Crown platform for the further growth and success Counsel, Principal Crown Counsel and of the organisation into the future. Crown Counsel attended and participated in the Workshop. A report was prepared by the In this regard, we have seen capacity building Workshop’s facilitators and sent to the FATF at the Secretariat in terms of new staff Secretariat for inclusion in their review and appointments. We welcomed Ms. Dawne analysis of the global Workshops for Judges Spicer who was appointed as the new and Prosecutors. Executive Director effective February 1, 2018. Ms. Spicer is a national of Trinidad and The hosting and shared funding of this Tobago and an Attorney at Law by Workshop was a significant way to support profession, with twenty-six years of our Members with the opportunity to experience in the area of AML/CFT. Her understand the need to effectively implement expertise and length of tenure with the their AML/CFT laws, the legal challenges CFATF, brings a wealth of knowledge and

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019 dedication to the organisation which she has (November 2018 Plenary), which allowed us served with distinction. to focus on our primary function as a FATF- Style Regional Body (FSRB). Mrs. Joanne Daniel was appointed Deputy Executive Director with effect from I urge Members to continue to actively September 1, 2018 and this was followed by participate in the Mutual Evaluation process the revision of the Secretariat’s as this is crucial to the work of the Organisational Chart and the appointment of organisation. Members should have full Ms. Magdalene Walcott as the Director of engagement on the issues discussed at Finance and Administration. Plenary meetings, in the Heads of FIU, CFATF Risk Trends and Methods (CRTMG) In addition to these senior management Working Group, CFATF International positions, the CFATF appointed a new Cooperation Review Group (CFATF ICRG), Translator, Ms. Ayana Jack, and also re- and the Working Group on FATF Issues designated and appointed Ms. Ellisha George (WGFI). Participation at the Global Network as an Administrative Officer specifically level is also encouraged through involvement dedicated to the Secretariat’s Mutual in FATF Plenary meetings. Evaluation Team. The COSUNs, the FATF Secretariat and all The successful strengthening of the CFATF’s Observers, have all been longstanding financial position through the Grant colleagues who continue to place tremendous th Agreement for the 11 European investments of human and financial resources Development Fund (EDF) European over the years to assist our jurisdictions in Union/CARIFORUM funding for the Fourth building critical AML/CFT capacity. We Round of Mutual Evaluations was another value their generosity and technical input and significant success attained during the period. remain committed to partnering with them throughout the Fourth Round of Mutual I was extremely pleased that the 11th EDF Evaluations and beyond. Grant agreement was successfully negotiated and signed and began implementation during The CFATF must continue to strike the my tenure. To this end, Project Manager balance between perfecting all processes Andrew Frection and Senior Project Officer necessary to ensure high quality Mutual Beverley Perez also became part of the Evaluations and completing the Fourth CFATF team. This project will provide the Round of mutual evaluations with an overall crucial funding for the Fourth Round of improved level of success. I thank you all for Mutual Evaluations’ related programmes for this opportunity to serve as Chairman and I CFATF beneficiary Members and also pledge my utmost support and that of the provide opportunities for participation for all government and people of the Co-operative CFATF Members. Republic of Guyana to all Members of the CFATF in the years to come. I wish all the I was also pleased to accept the offer of best to my successor, Mr. Dale Marshall, QC, funding from two Cooperating and MP Hon. Attorney General and Minister of Supporting Nations (COSUNs), Canada and Legal Affairs, Barbados and trust that under the United Kingdom for the funding of a his leadership, the CFATF will continue to Supervision Advisor who will work with positively address and overcome our Members and a range of stakeholders to challenges. develop the AML/CFT effectiveness of financial sector regulators and the entities Hon. Basil Williams SC, MP they supervise. Chairman of the CFATF Under my Chairmanship, we saw the November 2017- November 2018 presentations of the Mutual Evaluation Reports (MERs) of Antigua and Barbuda …………………………………………… (May 2018 Plenary) and the Cayman Islands

Foreword by the Executive Director

Ms. Dawne J. Spicer

We at the CFATF recognise that success is guidance, training, research papers and founded on partnership. During the past year, advice on AML/CFT matters. under my leadership, the Secretariat’s management and staff have taken every All of this requires increased and renewed opportunity to encourage participation both investments, a strong commitment to at the Secretariat level and at the Membership improve data collection and analysis, level in collaboration with Members through accountability frameworks for leaders, and the Steering Group and its sub-committees established responsibilities for all along with Plenary and the Council of stakeholders, including the private sector. Ministers. The process of collective participation had led to improvements in our We have made important advances as an primary work product; Mutual Evaluation organisation over the past year regarding the Reports; training and providing a high level implementation of governance and policy of technical assistance in an intense measures aimed at enhancing the programme of effectively mobilising our effectiveness of the Secretariat and of the limited resources. CFATF as a whole.

Ultimately, all our work is directed towards We have worked diligently towards ensuring Members are compliant with the improving our profile and image to the FATF Recommendations and effectively CFATF Members and the Global Network implementing their AML/CFT frameworks. through direct involvement in the discussions on relevant Regional issues through In that regard, the Secretariat remains conference, seminar and workshop committed to assisting Members in preparing presentations. for the rigours of the Fourth Round of MEVALs through continued assistance at the The Secretariat looks forward to working pre-assessment, assessment and post- with all Members in the coming years; assessment phases of the process. The together we can usher in a new era of Secretariat’s expert staff is provided resilience against global financial crimes.

……………………………… Ms. Dawne J. Spicer Executive Director 9

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Execution of the Chair's Work Programme

A key component of the Work Programme • Tech AML Seminar, Trinidad and during the term of Chairman Williams was Tobago ‘The Fourth Round of AML/CFT capacity building for CFATF Mutual Evaluations - Challenges and Members. This objective was successfully Opportunities in the Caribbean Basin accomplished through the execution of Region’ (March 21, 2018). CFATF Assessors training (January 22-26, • CFT Conference, France (April 25- 2018), the AML/CFT/CVE Workshop for 26, 2018). Judges (May 3-4, 2018) [See page 13 for • Compliance for Massy Board of further details on the outcomes of this Directors, Trinidad and Tobago meeting] and Chairman Williams’ and ED (May 11, 2018). Spicer’s participation in the Compliance Aid Anti-Money Laundering & Financial Crimes • Nevis Compliance Conference – ‘FATF Recommendations and Conference held on April 19, 2018 in Miami, Florida. Methodology for Assessing Effectiveness’ and ‘An Effective Compliance Programme’. (May 14- 15, 2018). • 9th Biennial Central Bank Seminar ‘De-risking by Correspondent Banks’ and ‘AML/CFT Standards and Expectations for MERs’, Trinidad and Tobago (June 12, 2018). • Judicial Workshop on Money Laundering and Asset Forfeiture, Trinidad and Tobago – ‘CFATF’s

Chairman Williams at ComplianceAid in Role and Status of Trinidad and Miami- April 2018 Tobago’s AML/CFT Efforts’ (July 24, 2018). The conduct of training by Secretariat staff • Countering the Financing of was another means of effective execution of Terrorism Workshop, Trinidad and the Chair’s Work Programme with staff Tobago ‘International Cooperation’ conduct of the following activities: and ‘FATF Terrorism and Terrorism Financing Requirements’ (August • Standards Training, St. Vincent and 14, 2018). the Grenadines (December 10-14, • FTS Virtual Currency Workshop, 2017). Cayman Islands ‘Overview of AML • National Risk Assessment (NRA) Best Practices on Payment Systems Workshop, Suriname (January 29- and Cryptocurrencies – Existing 31, 2018). Compliance and Risk Based Systems • Standards Training, Equatorial New (August 29, 2018). Guinea, Malabo - A collaboration by CFATF and GAFILAT to assist the CFATF’s Financial Strengthening Task Force on Money Laundering in Central Africa (Groupe d’Action This aspect of the Chairman’s work contre le blanchiment d’Argent en programme was executed through the Afrique Centrale (GABAC’s) successful granting of funding for the Fourth Spanish Member Equatorial New Round of Mutual Evaluations by the Guinea (February 12-16, 2018). European Union (EU). The preparation of the application for the Grant involved the

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019 extensive review, amendment and quality and consistency of CFATF MERs. consultation on the draft between the While all our Members who have completed Secretariat, Steering Group and the their Fourth Round of Mutual Evaluations Caribbean Forum of the African, Caribbean have been placed in Enhanced follow-up (See and Pacific Group of States (CARIFORUM). Annex 2) and effectiveness continues to The Grant Agreement for the 11th EDF present a challenge to our Members, there European Union/CARIFORUM funding for have been noticeable improvements in the the Fourth Round of Mutual Evaluations was level of technical compliance. signed on September 3, 2018. Fourth Round of Mutual Evaluations- In addition to the CFATF’s component of the Building Staff Capacity 11th EDF, Component B of the EU’s funding will be executed by the World Bank (WB) The internal training of staff on AML/CFT which will involve collaboration with the issues has been consistent with focus on areas CFATF and focuses on NRAs and other types that have provided some challenges in Fourth of technical assistance. In that regard, the WB Round MERs. These areas include the use of provided training on CFT through a two-day financial intelligence by competent training on the margins of the November authorities (Immediate Outcome 6), 2018 Plenary in Barbados. The training was confiscation including civil forfeiture, and funded for all CFATF Member countries. emerging issues such as cryptocurrency and data privacy. External staff training occurs CFATF Membership through attendance at FATF Working Group and Plenary meetings. To date, there has been no dedicated approach to increasing the Membership of Information Technology and Automation the CFATF. However, the Secretariat seeks sources of funding from countries that may The Secretariat’s website was updated by the be interested in partnering with the CFATF introduction of flowcharts on the Fourth on technical assistance and training issues so Round Mutual Evaluation Process, outreach that the benefit of expanded resources will by the CFATF to other FSRBs (Training in still be afforded to Members. Equatorial Guinea – GABAC), a Calendar of Events and other topics of interest. Image of the CFATF Additional improvements to the content and presentation of the website will continue. The application by Guatemala for Observer status in the CFATF was the primary matter Recognising the need to assess the under this item of the Chair’s work Secretariat’s Information Technology (IT) programme. At the September 2018 meeting functions, the Secretariat graciously received of the Council of Ministers the application by the support of Trinidad and Tobago via a Guatemala was approved and the country is review by Trinidad and Tobago’s Ministry of now in the process of formalising its National Security of the Secretariat’s IT processes and systems to execute their systems and functions. The review identified Observer status. In addition to this the need for the immediate purchase of a application, the application for Observer Firewall for the Network server. status submitted by CARICOM IMPACS Additionally, in an effort to ascertain the gaps was also approved by the Council of in the IT functions at the Secretariat, Trinidad Ministers. Further, the many representations and Tobago once again offered its services (see above at ‘Training Workshops and through the Ministry of the Attorney General Conferences’) by the Chair and the and Legal Affairs’ Information and Secretariat have positively enhanced the Communications Technology Department image of the CFATF during the Chairman’s (AGLA ICT). A six-month Action Plan was term. The image of the CFATF is also being developed, and the recommendations made addressed through the efforts to increase the by the AGLA ICT team were presented to the

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Steering Group for discussion on the way situation. The support offered in this area is forward. a testament of the strength and redounding benefits of both Member and COSUN During the period, the USA, agreed to assist collaboration with and support of the with the purchase of any software or CFATF. hardware that has been determined to be necessary to improve the Secretariat’s IT

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The CFATF AML/CFT/CVE Workshop for Judges and Prosecutors

The CFATF Workshop for Judges and Honourable Basil Williams, SC, MP, the Prosecutors was held during the period May Right Honourable Baroness Patricia 3-4, 2018 in Georgetown, Guyana. The Scotland, QC Secretary-General of the Workshop was funded by the Commonwealth, and His Excellency, the Commonwealth Secretariat, the Caribbean President of the Cooperative Republic of Development Bank (CDB) and the Guyana, Brigadier David Arthur Granger. Cooperative Republic of Guyana. The Honourable Basil Williams, SC, MP, Some of the presentations, sessions and Attorney General and Minister of Legal exercises that were covered during the two- Affairs, Guyana and Chairman of CFATF day session were as follows: hosted the Workshop in furtherance of the FATF President’s work programme for the Day 1 period 2017-2018 to engage in outreach to the Prosecutorial Services and the Criminal Session I - Mutual Evaluation Reports Justice System. (MERs) – CFATF Members level of compliance During the Fourth Round – Forty (40) participants from Member Recommendations 3 and 31 and countries comprising a Chief Justice and Immediate Outcomes (IOs) 6 and 7. fourteen (14) other Puisne Judges, one Chief Magistrate and twenty-four (24) Prosecutors, Objective: including; Directors of Public Prosecution, The presentation sought to provide delegates Deputy and Assistant Directors of Public with a very brief overview of the relevant IOs Prosecution, Senior Crown Counsel, and main Recommendations that cover the Principal Crown Counsel and Crown Counsel overall concept of the Fourth Round of attended the workshop. The workshop Mutual Evaluations i.e. technical compliance facilitators possessed a wealth of experience and effectiveness, ML, financial intelligence in the field of prosecution and adjudicating usage by competent authorities, and the on cases relative to ML, confiscation and powers of law enforcement and investigative countering terrorism and violent extremism. authorities. These individuals included: His Honour Judge Michael Hopmeier, (United Session II – Investigative Orders Kingdom); Mr. Justice David Fraser, (Jamaica); Andrew Mitchell, QC (United Objective: Kingdom); Dominic Barry, Specialist Brief overview of Orders that are essential to Prosecutor, Crown Prosecution Service the investigative process and Judges and (United Kingdom); Giovanni James, Legal prosecutors’ perspectives regarding the Advisor (Regional Security System-Asset Orders. Recovery Unit - (RSS-ARU); Shadrach Haruna, Legal Advisor, Commonwealth Session III – Prosecution and Secretariat; Mark Albon, Head of the Management of Money Laundering Cases. Countering Violent Extremism Unit Commonwealth Secretariat; Alexander Mills Objective: and Judge Hopmeier who drafted the case To explore pertinent issues regarding the scenarios. Presentations were also made by prosecution of money laundering cases. ED Spicer, and Mr. Pedro Harry, Law Enforcement Advisor, CFATF. Content: An overview of ML prosecutions and how The Workshop received a high level of they impact on the prosecutorial function commitment and visibility from the generally. Cooperative Republic of Guyana with speeches from the CFATF Chairman, Session IV – International Cooperation. 13

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overview was provided to the participants on Objective: the performance of Member countries To highlight and underline the importance of assessed thus far during the CFATF 4th international cooperation. round relative to Recommendation 4 and IO 8 and the deficiencies identified by the Content: assessment teams. The Presentation highlighted the best practices and underscored the importance of Session II - Panel discussion on Civil effective cooperation through informal Recovery and Non-Conviction Based liaison, preceding formal requests for Confiscation. assistance. Objective: Money Laundering Exercise – Reviewing To highlight the processes involved in civil practical examples. recovery and non-conviction-based confiscation. Objective: The objective of this session was to bring to Session III - Confiscation Exercise. fore the challenges faced by jurisdictions, including justice officials, in identifying Objective: appropriate cases of money laundering vis-a- By the use a case scenario, prosecutors were vis the extant legislation of their respective to discuss, prepare and present a restraint jurisdiction and the best practice approach to order application and the Judges were to addressing those challenges. consider the legal issues in relation to ex parte applications. Day 2 Following discussions with Presenters, Session I – Terrorism, Terrorist Financing Facilitators and participants, the following and Violent Extremism. Recommendations were developed:

Objective: 1. Ongoing training for Judges and The session explored the interconnection Prosecutors. between proceeds of crime and the fostering 2. Creation of an AML/CFT implementation of conditions conducive to terrorism, such as tool kit by the Commonwealth Secretariat. violent extremism, and the role of the justice 3. Focus on confiscation/asset recovery in all officials to ensure that the ‘life blood’ of such criminal matters. activity is severed. 4. Steps should be taken by prosecutors in the

region to ensure that they consider in every Mutual Evaluation Reports – Level of case whether a restraint order or confiscation CFATF Members’ compliance during the order should be applied for. Further in 4th Round – Recommendation 4 and deciding whether or not to use asset recovery Immediate Outcome (IO) 8. powers that are available to them, they should

make a file stating reasons why the powers Objective: were or were not being used. The presentation sought to provide the delegates with a brief overview of the 5. The Judges were encouraged to consider relevant FATF Standards, particularly their own domestic legislation and to Recommendation 4 and IO8 that cover the consider whether or not there was power for overall concept of the 4th Round of Mutual them to apply the confiscation scheme. Evaluations i.e. technical compliance and 6. Consideration should be given to effectiveness relative to confiscation and extending an invitation to local Bar other provisional measures. Further, an Associations for future training.

Photos from the Workshop

Presenters and Participants: from left to Chairman Basil Williams SC, MP, Hon. Attorney General and Minister of right: His Honour Judge Michael Legal Affairs of Guyana gives his opening remarks at the CFATF Hopmeier (United Kingdom), Workshop for Judges and Prosecutors was held during the period May 3- Valston Graham (DPP- St. Kitts- 4, 2018 in Georgetown, Guyana. Nevis) and Andrew Mitchell, QC (United Kingdom.

The Right Honorable, Baroness Patricia Scotland, QC, Members of the Head table with a cross-section of Secretary General of the Commonwealth delivering participants. her opening remarks.

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Visit of Chairman Williams to the CFATF Secretariat Office in Port-of-Spain, Trinidad and Tobago

The Honourable Basil Williams, SC, MP Chairman-in-office of the Caribbean Financial Action Task Force (CFATF) and Attorney General and Minister of Legal Affairs with the Members of Staff of the CFATF Secretariat Chairman Williams visited the office of the countermeasures to address ML/TF and PF. CFATF Secretariat on March 13, 2018 where Chairman Williams noted that ‘many of our he met with the Executive Director, Ms. regional economies have been deflected by Dawne Spicer, Deputy Executive Director, the underground economy through the Carlos Acosta and staff of the Secretariat. proceeds of crime from the five wars of During the visit he engaged the Secretariat globalisation - trafficking in persons, staff on the vision of the CFATF and trafficking in narcotics, trafficking in commended the hard work of the Secretariat weapons, money laundering and terrorist in fostering regional implementation of financing’.

Chairman Williams addressing the Secretariat staff where he noted their efficient work and urged them to redouble efforts to assist CFATF Members.

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Financial Overview

At the close of the Plenary year November 2018, the current staff at the CFATF Secretariat totaled fifteen (15) and comprised: the Executive Director, Ms. Dawne Spicer; two Deputy Executive Directors, Mr. Carlos Acosta and Mrs. Joanne Daniel; one Director Finance & Administration, Ms. Magdalene Walcott; two Legal Advisors, Ms. Ana Folgar and Mr. Rommel St. Hill; two Law Enforcement Advisors, Mr. Jefferson Clarke and Mr. Pedro Harry; one Financial Advisor, Mr. Roger Hernandez; one Administrative Manager, Ms. Julia James; one Research Officer, Mrs. Risha Pragg-Jaggernauth; one Administrative Officer, Ms. Ellisha George; two Translators, Mrs. Michele Le Blanc-Morales and Ms. Ayana Jack and one Accounting Assistant, Ms. Allysha Gibson.

In addition, Mrs. Joanne Hamid from the Central Bank of Trinidad and Tobago was seconded for a period of three (3) years with effect from November 2016 - November 2019 as a Financial Advisor.

The CFATF Secretariat provides support to the member jurisdictions of the CFATF, including: • Organising Plenary and working groups meetings, • Providing support to the CFATF Chairman, the Steering Group and CFATF delegations, • Preparing and producing policy papers to be discussed in working groups and/or the Plenary, • Co-ordinating of and participating in mutual evaluation missions and drafting the related assessment reports.

The CFATF Secretariat also liaises on an ongoing basis with the numerous CFATF partners, undertakes a representational role at professional events and provides information to the public and the media. Funding for the CFATF Secretariat is provided by the CFATF members on an annual basis.

Financial Overview2 Management of the organisation’s financial resources continues to be key to ensuring that the goals and objectives of the organisation are met. The Secretariat’s operational and administrative expenses are budgeted and approved annually by the Council of Ministers and membership annual contributions are set based on these expenditure levels. The donor community is also engaged and provides funding either on a project basis or for specific types of activities.

Operating Income and expenditure for 2018

The annual contribution for the financial year 2018 was approved at US$57,400 per Member. This was supplemented by the Reserve Fund to cover an approved expenditure for 2018 of US$1,489,298. All Members paid their annual contribution before the end of the Chair’s term with minimal small balances to be cleared due to bank charges. Savings experienced for 2018 were mainly due to several staff changes as well as vacancies that arose during the period.

2 It should be noted that the fiscal year for the CFATF is January-December. The Annual Report period is different and covers the term of each Chair i.e. November to November each year. 17

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Donor Funded Projects

The donor community supported and funded several activities during the period under review. See below for a list of activities which occurred:

Activity Donor Country/ Organisation Type of relationship Attendance of CFATF Staff to various United States COSUN meetings (e.g. GELAVEX meeting; GAFILAT Plenaries; ARIN CARIB Steering Group and annual meetings; FATF Plenaries) CFATF Assessors training United States COSUN Standards training for Dominica Canada COSUN GAFILAT/CFATF Assessors training Mexico and Spain COSUN (participants and facilitator travel costs) Workshops for Spanish Members inclusive Spain COSUN of: • GAFILAT/CFATF Workshop on Beneficial Ownership • Régimen General y supervisión de APNFDs Jornada de Puertas Abiertas (Training for El Mexico COSUN Salvador participants) CFATF Judges and Prosecutors Workshop Commonwealth Secretariat Observer (COMSEC) and the Caribbean Organisations and Development Bank (CDB) and CFATF Member the Cooperative Republic of Guyana

The Secretariat also manages the grants of the two (2) projects funded by the EU through the 10th and 11th EDF financing agreements with CARIFORUM. See pages 20 and 21 for further information.

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Donor support

The COSUNs have made very valuable Michele, Principal Specialist, contributions to the successes of the CFATF Innovation for Citizen services over the years by their critical role in the (ICS), Institutions for Development growth and development of the CFATF, (IFD). Mr. de Michele outlined the contributing both human and financial IDB’s Technical Assistance Program resources to all CFATF endeavours. and the work of the IDB with the WB in Guyana on its NRA and with the CFATF Member countries have been Financial Services Commission in encouraged to provide detailed matrices on Jamaica was highlighted, in addition their Technical Assistance and Training to two publications relevant to the Needs. Based on these submissions, region on De-risking and Beneficial discussions would continue with the Ownership. COSUNs and other partners in the donor community for the delivery of relevant assistance to Members in support of the iii. Presentation on Training available Fourth Round of Mutual Evaluations using from the Interdepartmental Anti- available funds and those to be provided Drug Training Centre, Martinique– within the framework for delivery and Deputy Director, The Inter- reporting as agreed by the Parties. Twenty- ministerial Center for Anti-Drug one (21) member countries of the CFATF Training (CIFAD), Bruno Francerie submitted their technical assistance and concerning the role and objectives of training needs in May 2018 and on Tuesday CIFAD and that their contact May 29, 2018 at the Donors Forum of the information was shared with the CFATF XLVII plenary held in Port-of-Spain, Forum. Trinidad and Tobago, the following presentations were made: iv. Presentation on Development of an AML/CFT Strategy: Cayman Islands i. Presentation highlighting details of a by Francis Arana Head, Anti-Money Seminar to be held in November Laundering Unit Portfolio of Legal 2018 based on the submission of Affairs, Cayman Islands Members’ needs by the World Government relating to addressing Bank’s Representative Ms. Tanjit the challenges of developing national Sandhu, Financial Sector Specialist, AML/CFT strategies from a Finance and Markets, World Bank completed NRA perspective. Group. The EU, through the 10th and 11th EDF also ii. Presentation on Technical Assistance provides valuable technical assistance and available from Inter-American training to the CFATF Members. See pages Development Bank – Roberto de 20 and 21 for further information.

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European Development Fund (EDF) 10th EDF Accreditation and Training Project

The Accreditation and Training project is a Source Internet Investigations were three-year project which is fully funded by conducted by Mr. Jon Blake, the Managing the EU through the 10th EDF. This Director of Online Operations Limited of programme commenced on September 1, Congleton, Cheshire, United Kingdom with a 2016, following the signing of the Grant total of 52 individuals from 15 countries Contract on June 13, 2016 and the receipt of being trained. the first tranche of funding in August 2016. Session 1: held at Halcyon Cove, St Johns, Thus far, the project team has hired the Antigua on April 30- May 1, 2018. project administration staff; engaged with Session 2: held at Halcyon Cove, St Johns, service providers to develop training Antigua on May 3-4, 2018. material; developed and launched a web Session 3: held at Knutsford Court Hotel, portal for the registration of trainees; Kingston Jamaica on May 7- 8 2018. identified potential regional trainers and conducted training workshops for training The broad learning outcomes for this training analysts, investigators and regional trainers. were:

A project website (https://cfatf- • Finding information, you would expect gafic.org/index.php/accreditation) with an e- to be confidential; learning platform through which the pre- • The use of social networks and media as training course material and online an investigative tool; assessment of participants are administered • Diving deep for business information; was also developed. This project website • Protecting your identity while searching facilitates the online registration of all covertly; persons wishing to be trained under the • The use of online privacy and anonymity project and includes an Alumnus of the tools; trainers, accredited analysts and • Use of online database systems; investigators. • Exploiting Internet search engines and

tools; Of the ten (10) training workshops conducted • Archiving methodology and tools and since its commencement in 2016, during the methods for obtaining archived reporting period, November 2017- November webpages and hidden information; 2018, eight (8) training workshops for • Understanding geolocation methods; analysts and financial investigators on Financial Analysis and Open Source Internet • Investigation of digital images and Investigations were conducted with a total of • Analysing, organising and preparing for one hundred and twenty-seven (127) persons written reports. being trained.3 th The 10 EDF Programme will conclude on During the period April 30 to May 8, 2018, August 31, 2019. three two-day training sessions of Open

3 This figure is subject to review and will be amended as necessary in subsequent draft of the Annual Report. 20

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11th EDF – EU/CARIFORUM Assists CFATF Implementation of the Mutual Evaluation Programme

Ms. Daniela Tramacere, EU Ambassador to Barbados, Ms. Dawne Spicer, Executive Director, CFATF and Mr. Andrew Frection, Project Manager, CFATF meet at the CFATF XLVIII Plenary in Barbados.

The EU and the CFATF signed a Grant levels of compliance with the FATF 40 Agreement to enhance the Region's capacity Recommendations. to comply with standards relating to AML/CFT. This will be undertaken via the The Project is also expected to undertake a implementation of the Mutual Evaluation series of workshops and seminars to build Programme which will evaluate compliance technical capacity, carry out public education in the financial and related sectors in CFATF and awareness activities, and develop an member countries, to ensure that Information Communication Technology international standards are adhered to. platform called Vision 2022 which will allow CFATF Members to access resource One of the main actions under the 11th EDF databases. will be assisting countries in improving their

Year in Pictures

Members of the head table at the CFATF’S XLVI Plenary and Working Groups Meeting held in Guyana Chairman Basil Williams SC, MP, Hon. Attorney General of Guyana November 2017. chairs the Council of Ministers Meeting in Miami, Florida on From left to right, Hon. Attorney September 12, 2018. From left to right also pictured are: Ms. General of Trinidad and Tobago, Hon. Magdalene Walcott, Director of Finance and Administration, Ms. Faris Al-Rawi, Immediate Past Chair Cheryl Greenidge, Director (Ag.) Bank Supervision Department, 2016-2017, former Executive Director Central Bank of Barbados, the Honourable Dale Marshall Q.C., M.P., of the CFATF, Mr. Calvin Wilson, the Attorney General and Minister of Legal Affairs of Barbados and Honourable Attorney General, of the Executive Director of the CFATF, Ms. Dawne Spicer. Turks and Caicos Islands and Chairman of the CFATF 2016-2017, Rhondalee Braithwaite-Knowles and the Honourable Basil Williams, SC, MP, Attorney General and Minister of Legal Affairs, of Guyana and Deputy Chairman of the CFATF 2016-2017.

Mr. Pedro Harry, Law Enforcement Advisor, delivering his presentation on “The Importance of International Cooperation to combat ML, associated predicate offences and TF- Application of the FATF Recommendations and achieving effectiveness” at the ARIN- CARIB’s 4th Steering Group Meeting and 2nd Annual General Meeting held in Saint Vincent and the Grenadines during the period 14- 16 November 2018. Entertainment provided by Guyana during the CFATF’S XLVI Plenary and Working Groups Meetings held in the jurisdiction in November 2017.

Entertainment provided by Entertainment provided by Guyana during the CFATF’S Guyana during the CFATF’S XLVI Plenary and Working XLVI Plenary and Working Groups Meetings held in the Groups Meetings held in the jurisdiction in November 2017. jurisdiction in November 2017.

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From left to right: Juan Cruz Ponce, Technical Expert GAFILAT; Ana Folgar, Legal Advisor CFATF and Zenon Obiang, ANIF G.E. Director.

The National Financial Investigation Agency of Equatorial Guinea (ANIFGE), in coordination Members of the head table at the CFATF’S XLVI with the Caribbean Financial Action Task Force Plenary and Working Groups Meeting held in (CFATF) and the Financial Action Task Force of Guyana November 2017. Latin America (GAFILAT), held the training seminar: International standards to combat From left to right, Ms. Celeste McCalla and Mrs. money laundering, terrorist financing, and the Vyana Sharma (Co-chairs WGFI), Ms. Dawne financing of the proliferation of weapons of mass Spicer, Deputy Executive Director (2016-2017), Mrs. destruction from February 12-16, 2018, in Joanne Daniel, Financial Advisor (2017). Malabo, Equatorial Guinea.

The FATF TREIN recognised the very valuable assistance from the Secretariat of the CFATF (Deputy Executive Director, Mr. Carlos Acosta, second from left in the front row), the World Bank, the University of Toronto - Munk School of Global Affairs and Public Policy, and the Kingdom of Spain, who provided trainers to support the specialists from Hon. Basil Williams, SC, MP, Attorney General the FATF TREIN in delivering the training. and Minister of Legal Affairs, of Guyana and Deputy Chairman of the CFATF 2016-2017 The FATF TREIN delivered its FATF Standards greets the Hon. Attorney General of Trinidad Training course, in Spanish for the first time from 1- and Tobago, Hon. Faris Al-Rawi, Immediate 5 October 2018. The course was delivered to 39 Past Chair 2016-2017 ahead of the start of the participants from 20 jurisdictions, which included all CFATF’S XLVII Plenary and Working Groups Latin American countries, two jurisdictions from Meeting in Trinidad and Tobago May 2018. Africa as well as a European country (Spain).

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Training and Events 2018 During the reporting period, the CFATF reasonableness of its NRA to determine continued to engage in training and technical whether the country has sufficiently Assistance and capacity building for understood the ML and TF risks and whether Members. A number of Assessor and it has taken commensurate mitigating action. assessed country training courses were also They also learn more about the information conducted as the quality of the mutual they should request during a mutual evaluation process relies on the participation evaluation to determine whether the country of relevant and experienced experts from the has implemented the required legal, Membership in each assessment team. To regulatory and operational framework. Most ensure a consistently high quality of all importantly, they learn to identify the mutual evaluations, the CFATF organises evidence needed to demonstrate that a regular training sessions for future assessors. country’s efforts are effective in tackling ML Only trained assessors with relevant and TF. The aim of the mutual evaluation is experience in the field can join an assessment not only to identify where a country’s team. The assessor training sessions explain strengths and weaknesses lie but to also the mutual evaluation in great detail. The risk provide the assessed country with clear and assessment is the foundation block for targeted recommendations that will help it to building a framework that mitigates the risks strengthen its measures swiftly and to which each country is exposed. effectively. Consequently, the training gives potential assessors the necessary tools to During Assessor Training, potential assessors successfully undertake a mutual evaluation learn how to critically analyse the country’s mission. risk and context and assess the

Assessor and assessed country training and other AML/ CFT Trainings and workshops delivered and attended for the period are included in the table below.

TRAINING AND EVENTS DATES LOCATION

FATF Standards Training November 29-December Turks and Caicos Islands 1, 2017 FATF Standards Training December 11-13, 2017 St. Vincent and the Grenadines FATF TREIN Standards Training 11-15 December, 2017 Busan, South Korea CFATF Assessors’ Training 22-26 January Georgetown, Guyana NRA Workshop 29-31 January Paramaribo, Suriname CFATF/GAFILAT - FATF Standards Training 12-16 February Malabo, Equatorial Guinea FATF Plenary and Working Groups 17-23 February Paris, France TECH AML Seminar – Enforcement and Compliance 21 March Port of Spain, Trinidad and Tobago CFATF/GAFILAT – Workshop on the Use of Financial Intelligence 10-12 April Lima, Peru Pre- Assessment Training 11-13 April Hamilton, Bermuda ComplianceAid - Fourth Caribbean Anti-Money Laundering & 19-20 April Miami, Florida Financial Crimes Conference ARIN-CARIB Steering Group Meeting 24-25 April Miami, Florida CFT Conference 25-26 April Paris France CFATF Judges and Prosecutors Workshop 3-4 May Georgetown, Guyana FATF Standards Training 8-10 May Roseau, Dominica

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TRAINING AND EVENTS DATES LOCATION

AML/CFT Awareness Seminar and Training Workshop “Improving 14-15 May Nevis, St. Kitts and Nevis Transparency and Accountability – Fostering Confidence in today’s Regulatory Environment”. Pre-Onsite Training for Haiti’s MEVAL 12-13, 18 June Online CFATF XLVII Plenary and Working Groups 27-31 May Port of Spain, Trinidad and Tobago FATF TREIN Standards Training 4-9 June Busan, South Korea FATF/MENAFATF Plenary and Working Groups 24-29 June Paris, France Onsite visit – Haiti’s Mutual Evaluation 25 June to 6 July Haiti Joint CFATF/FATF/IMF Assessors Training 9-13 July Port of Spain, Trinidad and Tobago Régimen General y supervisión de APNFDs 16-20 July El Salvador GAFILAT Plenary 23-27 July Panama City, Panama Pre-Onsite Training for Turks and Caicos Islands’ 14-17 August Port of Spain, Trinidad and MEVAL Tobago Pre-Onsite Training for Bermuda’s MEVAL 11-14 September Online & Port of Spain, Trinidad and Tobago GAFILAT/CFATF/FATF Assessors Training 27-31 August Santiago, Chile CFATF Steering Group and Ministerial Meeting 3-4 September Miami, Florida JG of the Americas Face-to-Face meeting (The Bahamas and 5-6 September Miami, Florida Trinidad and Tobago) Onsite visit – Turks and Caicos Islands’ Mutual Evaluation 10-21 September Turks and Caicos Islands Onsite visit – Bermuda’s Mutual Evaluation 24 September to 5 Bermuda October Face-to-face meeting – Cayman Islands’ Mutual Evaluation Report 27-28 September Grand Cayman, Cayman Islands FATF TREIN Standards Training (Spanish) 1-5 October Busan, South Korea FATF Plenary and Working Groups 14-19 October Paris, France CFATF XLVIII Plenary and Working Groups 18-22 November Bridgetown, Barbados

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Overview of the Mutual Evaluation Programme and the Plenary Process

An effective Mutual Evaluation Programme Thus, the assessment results in two sets of is the primary objective of the CFATF’s work ratings, one set of 40 ratings that indicate how as it is one of the mechanisms by which the well the assessed country has met the Secretariat ensures that each Member State technical compliance requirements of the fulfils their obligation undertaken as a FATF Recommendations, and one set of 11 signatory of the CFATF Memorandum of ratings that correspond to the level of Understanding (MOU). effectiveness of its efforts to protect the financial system from the threats of Each mutual evaluation is an in-depth ML/TF/PF through implementation. assessment that will take into account the country’s unique risk and context and The CFATF is currently conducting a Fourth determine whether the country has Round of Mutual Evaluations for its implemented the technical requirements of Members based on the FATF each of the 40 FATF Recommendations. At Recommendations (2012), and the the same time, the assessment team will look Methodology for Assessing Compliance with at whether, in practice, the assessed country’s the FATF Recommendations and the legal, regulatory and operational framework Effectiveness of AML/CFT Systems (2013), is delivering the expected results, in other as amended from time to time. The CFATF words, measure its effectiveness, so that it Procedures for the Fourth Round of Mutual can protect financial systems and the broader Evaluations form the basis for the conduct of economy from the threats of money mutual evaluations and follow-up by all laundering and the financing of terrorism and assessment bodies. proliferation. (See Annex 2 for a detailed illustration of the Mutual Evaluation Process)

Plenary Meetings

The principal responsibility of the CFATF During the period November 2017- Plenary is oversight of the Mutual Evaluation November 2018, the CFATF conducted three Programme. The CFATF Plenary discusses plenary meetings. the assessment team’s findings, including the proposed ratings and recommended priority 1. The CFATF’S XLVI Plenary and actions, following which; the report Working Groups Meetings which undergoes a quality and consistency review. was held during the week of This review is mandatory for all mutual November 12-16, 2017 in Guyana evaluations, regardless of the assessing body. where the Mutual Evaluation Report The review ensures a consistently high of Barbados was adopted. standard for all assessments conducted in the FATF Global Network. The assessment 2. The CFATF XLVII Plenary and process ends when a report has successfully Working Groups Meetings which completed the quality and consistency was held during the week of May 27- review. If the review reveals inconsistencies, 31, 2018 in Trinidad and Tobago then the report is referred back to the where the Mutual Evaluation Report assessing body. After a successful of Antigua and Barbuda was completion, the report is ready for adopted. publication. 3. The CFATF XLVIII Plenary and The CFATF Plenary meets at least twice Working Groups Meetings which annually and is the ultimate decision-making was held during the week of body on all technical issues relating to MERs, November 19-22, 2018 in Barbados FURs and adoption of the revised FATF where the Mutual Evaluation Report Recommendations. of the Cayman Islands was adopted.

CFATF XLVI November 2017 Plenary Highlights

Members of the head table at the CFATF’S XLVI Plenary and Working Groups Meeting held in Guyana November 2017. From left to right, the Honourable Attorney General, of the Turks and Caicos Islands and Chairman of the CFATF 2016-2017, Rhondalee Braithwaite-Knowles, OBE; the Honourable Basil Williams, SC, MP, Attorney General and Minister of Legal Affairs of Guyana and Deputy Chairman of the CFATF 2016-2017; Deputy Executive Director of the CFATF 2016-2017 Ms. Dawne Spicer; Ms. Dulcie James, Commissioner, Financial Services Commission, Montserrat; and Ms. Celeste McCalla and Mrs. Vyana Sharma (Co-chairs WGFI). 27

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Participants at the CFATF’S XLVI Plenary and Working Groups Meeting held in Guyana November 2017.

The Honourable Basil Williams, SC, MP, Attorney General and Minister of Legal Affairs, of Guyana sits with Members of the Guyanese delegation during the CFATF’S XLVI Plenary and Working Groups Meetings held in Guyana, November 2017.

At the CFATF XLVI Plenary and Working the Mutual Evaluation report following Groups meeting held in Guyana, the main discussions at both the CFATF Working issues addressed were: Group on FATF Issues (WGFI) and at Plenary. Discussion of the MER of Barbados Updates were also provided regarding the The CFATF Plenary discussed the MER of ongoing mutual evaluation status of the Barbados which set out the level of countries in the Third-round follow-up effectiveness of the country’s AML/CFT process (Haiti, St. Vincent and the system and their level of compliance with the Grenadines and St. Maarten). With respect to FATF Recommendations. Plenary approved the Fourth-Round mutual evaluations, the

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019 status of Trinidad and Tobago, Jamaica, The (3) plenaries after adoption of the MER to Bahamas, Antigua and Barbuda, Turks and two (2) plenaries after adoption in order to Caicos Islands, Haiti and Bermuda were make the FFUR available for consideration at presented. In addition, the Secretariat also the end of the FATF one-year observation signaled to the Plenary the issue surrounding period. This is important since the FFUR is the impact of hurricanes Irma and Maria on one of the sources used by the FATF Joint some Members’ ability to have their onsite at Group in its determination as to whether a the scheduled times and on Membership country will undertake the FATF’s ICRG participation in the Fourth Round of mutual Action plan or be referred to the CFATF for evaluations. monitoring. The other amendments approved primarily ensured consistency between the There was a presentation on the Technical narrative of the Procedures and the relevant Compliance Matrix with respect to tables in the appendices. Recommendations 24 and 25 on Transparency and Beneficial Ownership of The Plenary also accepted the proposal to end Legal Persons/Arrangements by the the work of the CFATF Review Working Secretariat. The purpose of the Matrix was to Group (CRWG). The decision was based serve as a reference source for both countries upon the Secretariat’s response to the and assessors alike, and its contents are likely recommendations of the CRWG report to change over time. The information was presented one year prior on methods to derived from the findings published in each strengthen the ME process. country’s respective MERs and also included the latest legislative developments. Updates and Outcomes of the FATF June and October 2017 Plenaries were also presented Whilst eight Amendments to the CFATF at the following CFATF Working Group Fourth Round Mutual Evaluation Procedures Meetings: the CFATF ICRG, the WGFI, were approved by the Plenary, the most which covers the work of the Policy critical reduced the reporting time for the Development Group (PDG), Global Network First Follow-Up Report (FFUR) for those Coordination Group (GNCG) and countries in enhanced follow up (See Annex Evaluations and Compliance Group (ECG), 2) which also meet the FATF one-year the CRTMG and the Heads of FIU Forum observation criteria. Plenary agreed to meetings. reduce the reporting of the FFUR from three

CFATF XLVII May 2018 Plenary Highlights

Participants at the CFATF’S XLVII Plenary and Working Groups Meeting in Trinidad and Tobago May 2018.

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The CFATF XLVII Plenary and Working The main issues dealt with by this Plenary Groups meeting was also held under the were: Chairmanship of the Honourable Basil Discussion of the MER of Antigua and Williams, SC, MP, Attorney General and Barbuda Minister of Legal Affairs, of Guyana. The MER of Antigua and Barbuda was discussed and adopted by the Plenary.

Plenary Discussion of the Mutual Evaluation Report of Antigua and Barbuda at the CFATF’S XLVII Plenary and Working Group Meetings in Trinidad and Tobago May 2018.

Combatting terrorist financing, including of CFT measures in their jurisdiction at each the adoption of a new counter-terrorist Plenary. The presentations should focus on financing operational plan (i) measures being taken to address terrorist financing risk; (ii) any best practices and In February 2018, the FATF announced the challenges in implementing CFT development of their counter-terrorist mechanisms and (iii) national and financing operational plan which will focus international cooperation for CFT. its future efforts in responding to the current terrorist financing risks and ensuring that its Donors Forum global standards and their effective implementation continue to protect the The Donors forum was held on May 29, 2018 integrity of the financial system. The Plan where a report was highlighted by the also called for FSRBs to develop their own Secretariat on technical assistance and CFT Operational Plans. In that regard, the training that had been provided and planned CFATF Plenary agreed to include the topic of based on the matrices of technical assistance the CFT Operational Plan as a standing item and training needs submitted by twenty-one on the CFATF Plenary agenda during which member countries. two (2) Members will be asked to present on (See page 19 for more information on the their legal requirements and implementation support rendered by the Donor community)

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Hon. Chairman Williams addresses participants at the CFATF’S XLVII Plenary and Working Group Meetings in Trinidad and Tobago May 2018.

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CFATF XLVIII November 2018 Plenary Highlights

evaluation were addressed and the final conclusion on the re-ratings. Updates about the ongoing mutual evaluation status of Haiti, the Turks and Caicos Islands, Bermuda, Venezuela and St. Lucia were provided.

Plenary Discussion of the Mutual Evaluation Discussion of the adoption of the CFATF Report of the Cayman Islands at the CFATF’S ICRG Procedures for the Fourth Round of XLVIII Plenary and Working Group Meetings AML/CFT Mutual Evaluations, which will in Barbados November 2018. bolster and provide greater clarity to the

existing Follow-Up Process was also The CFATF XLVIII Plenary and Working conducted during the plenary. Group meetings held in Bridgetown,

Barbados during the period 19-23 November 2018 were the last over which the Hon. Chairman Basil Williams SC, MP, Hon. Attorney General and Minister of Legal Affairs of Guyana presided as Chair.

The main outcomes of this Plenary were:

Discussion of the MER of the Cayman

Islands: Participants at the CFATF’S XLVIII Plenary and Working Group Meetings in Barbados, The CFATF Plenary discussed the MER of November 2018. the Cayman Islands and the next step in the process is its preparation for the post-Plenary CFATF CFT Operation Plan Quality and Consistency process and will be published once the process is concluded. Trinidad and Tobago and Belize made presentations of their CFT work in line with Discussion of the 1st enhanced FUR for the approved CFT Operation Plan adopted at the mutual evaluation of The Bahamas, in the CFATF XLVII May 2018 Plenary. which the country achieved technical compliance re-ratings Updates of the FATF June and October 2018 Plenaries The CFATF Plenary discussed the FFUR for the Fourth Round that included a request for Outcomes of the FATF June and October re-ratings for technical compliance. The 2018 Plenaries were presented at the FFUR highlighted progress that The following CFATF Working Group Bahamas made since the adoption of its MER Meetings: CFATF ICRG, WGFI, which in 2017. The Bahamas has made progress covers the work of the Policy Development since the publication of its MER. The CFATF Group (PDG), Global Network Coordination Plenary agreed to re-rate The Bahamas’ Group (GNCG) and Evaluations and technical compliance with a number of FATF Compliance Group (ECG), the CRTMG and Recommendations to reflect the country’s the Heads of FIU Forum meetings. Some of progress since its MER was adopted and its the topics discussed were the amendments to current level of technical compliance. After Rec. 15 (New Technologies) which now the completion of a quality and consistency includes a new paragraph to deal with Virtual review, the CFATF published the FFUR Assets (the Glossary was also amended to which summarises the analysis of how include the definition of Virtual Assets and deficiencies identified during the mutual 32

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Virtual Assets Service Providers) and the the changes to the Methodology regarding future work that the FATF will undertake Rec. 2 and Immediate Outcomes 1, 3 and 4. (which will include an Interpretative Note and amendments to the Methodology) and

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Council of Ministers Meeting

The Council of Ministers (COM) Meeting Communications Strategy Plan and during the reporting period November 2017- Action Items were also approved by the November 2018 was held in Miami, Florida COM and its implementation is to be on September 12, 2018. The COM decided monitored by the Secretariat. that Antigua and Barbuda will be the incoming Deputy Chair of the CFATF for the • The Election of Steering Group Members period 2018/2019 and will be represented in for the period November 2018 to that post by Col. Edward Croft, Director of November 2020. the Office of National Drug and Money Laundering Control Policy, Antigua and • Regarding CFATF Resources, the COM Barbuda. discussed the recruitment of CFATF Secretariat staff and a revised Also, at the Meeting, the proposal for the Organisational Chart with re-designated composition of the Steering Group (SG) for posts of Director Finance and the period November 2018/November 2020 Administration and Administrative took place and it was later ratified that the Officer. Physical Resources and an Members for the period 2018-2020 will be: - Action Plan to improve the efficiency and effectiveness of the CFATF’s • Barbados – Chairman Information Technology functions were also discussed. With respect to financial • Antigua and Barbuda – Deputy resources, the Operational Work Plan Chairman and Budget 2019 were also discussed. • Guyana – Immediate Past Chair • Details were provided to the COM on the • Grenada - Organisation of Eastern Fourth Round Mutual Evaluation Caribbean States Programme, specifically on the Third Round Follow up/ICRG Processes, the • Suriname – Dutch Speaking Fourth Round Follow up/ICRG Countries Processes and the Fourth Round of • The Bahamas, Bermuda and Mutual Evaluations. Jamaica - Three Countries at Large • Technical Assistance and Training • Virgin Islands – Overseas Requirements regarding the 10th and 11th Territories EDF were highlighted, with the signing • Venezuela – Spanish Speaking of the Grant Agreement on September 3, Countries 2018 and the recruitment process commenced for the Project Manager and • Trinidad and Tobago – Other Senior Project Officer being noted. Countries • The COM deliberated on the applications • Canada - COSUNs Representative for Observer Status before them and Guatemala and CARICOM IMPACS Highlights of this meeting: were approved as Observers of the CFATF. • The Planning Committee (PLC) will review the Strategic Plan 2018-2022 with • The COM approved the proposal for the a view to amending the Operational timelines and contents of the CFATF Work Plan and to ensuring that the Annual Reports. increased budget expenditure from 2020 and beyond is minimized. The 34

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Looking Ahead providing the support to ensure the continued building of a strong and respected CFATF. I Our successes during the 2017/2018 period recognise the hard working and dedicated would not have been possible without the staff at the Secretariat who all contribute to collective efforts of all Members and I pledge the efficient functioning of the organisation to support Hon. Attorney General Marshall of and the effective representation of the Barbados as incoming Chair and Deputy Region’s interests in various fora across the Chair Col. Edward Croft, Director of the globe, to the benefit of all our Members and Office of National Drug and Money our regional and international partners. Laundering Control Policy, Antigua and Barbuda as the incoming Deputy Chair. Hon. Basil Williams SC, MP These gentlemen and the CFATF Chairman of the CFATF organisation can be assured that during their November 2017- November 2018 November 2018 - November 2019 tenure as leaders and beyond, I remain committed to ……………………………………………

The Honourable Basil Williams, SC, MP, Attorney General and Minister of Legal Affairs, Guyana and Chairman of the CFATF for the November 2017- November 2018 period exchanging a handshake with the Honourable Dale Marshall Q.C., M.P., Attorney General and Minister of Legal Affairs of Barbados the CFATF Deputy Chair for the period.

Caribbean Financial Action Task Force February 26, 2019

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Annex 1- The Mutual Evaluation Process (Flowchart)

The flowcharts below highlight the processes and are divided as follows:

I. Stage I: The Pre-Onsite Process II. Stage II: The Post-Onsite Process

I. Stage I: The Pre-Onsite Process

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II. Stage II: The Post-Onsite Process

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Annex 2 - CFATF Follow-up Process Flowchart Regular Follow-up

ADOPTION OF

THE MER BY PLENARY FUR is presented at the CFATF Plenary for Country is placed on INFORMATION ONLY REGULAR FOLLOW-UP based on the MER results Secretariat reviews the information and determines that progress HAS been made COUNTRY IS INCLUDED IN THE PUBLIC STATEMENT FUR sent to the Country does NOT (acknowledging that Secretariat 2 SEEK re-rating progress has been made) MONTHS before Plenary

st 1 FUR is presented 5 CFATF Plenary PLENARIES after the determines if country adoption of the MER Secretariat reviews the moves to ENHANCED information and determines that FOLLOW-UP and if progress HAS NOT been made 2nd FUR presented 2 additional measures are PLENARIES after 1st put in place FUR

3rd FUR presented 2 PLENARIES after 2nd FUR COUNTRY IS

INCLUDED IN THE PUBLIC STATEMENT SEE TC RE-RATING (mentioning that progress Country SEEKS re- PROCESS has not been made) ratings FLOWCHART

If the jurisdiction lowers its compliance to a level that Plenary considers equivalent to NC/PC on any one or more of R.3, 5, 10, 11, 20 it will be placed in ENHANCED FOLLOW-UP

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

Enhanced Follow-up

ADOPTION OF THE MER BY PLENARY

Country is placed on ENHANCED Secretariat reviews the FOLLOW-UP based on information and FUR is presented at the the MER results determines that progress CFATF Plenary for HAS been made INFORMATION ONLY

Country does NOT FUR sent to the COUNTRY IS INCLUDED IN SEEK re-rating Secretariat 2 MONTHS THE PUBLIC STATEMENT before Plenary (acknowledging that progress 1st FUR is presented 3 has been made) PLENARIES after the adoption of the MER (or 2 Plenaries if it meets the FATF ICRG referral Secretariat reviews the CFATF Plenary and prioritisation criteria) information and determines determines if country stays that progress HAS NOT been in ENHANCED 2nd FUR presented 2 made FOLLOW-UP and if PLENARIES after 1st additional measures are FUR put in place

3rd FUR presented 2 PLENARIES after 2nd FUR COUNTRY IS INCLUDED IN THE Country SEEKS PUBLIC STATEMENT SEE TC RE-RATING re-ratings (mentioning that progress PROCESS FLOWCHART has not been made)

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

FATF ICRG Process Flowchart

ADOPTION OF Jurisdiction meets referral THE MER BY Jurisdiction meets referral and prioritisation criteria BUT NOT the prioritisation THE CFATF criteria

Referral to FATF ICRG for Referral to FATF ICRG for Observation (at the next Observation (at the next FATF Plenary). One-year FATF Plenary). One-year Observation Period starts Observation Period starts

Observation Period ends (one year from the referral to Observation Period ends the FATF ICRG) (one year from the referral to the FATF ICRG)

JG drafts POPR to FATF ICRG (after the face to face Jurisdiction meets the Jurisdiction does not meet with the jurisdiction) prioritisation criteria the prioritisation criteria

JG presents POPR to the next FATF ICRG meeting (with an Jurisdiction will not be monitored Action Plan if after their analysis of the “Big 6” and other if the by the FATF and remain in the country had 20 or more total PC/NC ratings and assesses progress pool but will only be in the CFATF in each IO rated low or moderate and the jurisdiction did not make MER follow-up process sufficient progress) Jurisdiction DOES NOT PROVIDE High-level political commitment it goes to the Public Statement FATF ICRG determines FATF ICRG determines that jurisdiction HAS that jurisdiction has NOT JG monitors progress and makes MADE ENOUGH MADE ENOUGH recommendations to the FATF ICRG PROGRESSAnnex 3 PROGRESS Jurisdiction PROVIDES (updates provided at every FATF High-level political Plenary, but a determination as to the commitment it goes to the progress to the Action Plan is done one Compliance document year after)

The jurisdiction is referred back to the CFATF for MER follow-up process If progress is made in the If no progress is made Action Plan, move up the in the Action Plan, list, propose an on-site move down the list, visit and exit the FATF Public statement and ICRG process application of Rec. 19

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

Annex 3 -Observer Organizations

• Asia Pacific Group Secretariat • Association of Caribbean Commissioners of Police • Caribbean Customs Law Enforcement Council • Caribbean Development Bank • CARIFORUM • Caribbean Regional Technical Assistance Centre • CARICOM Secretariat • CARICOM IMPACS • Central American Bank for Economic Integration (CABEI) • Commonwealth Secretariat • Eastern Caribbean Central Bank • Eastern and Southern Africa Anti Money Laundering Group • EGMONT Group • European Union • Federal Republic of Germany • Financial Action Task Force • Financial Action Task Force of Latin America • Group of International Finance Centre Supervisors • Inter-American Development Bank • International Monetary Fund • Interpol • MONEYVAL • Organization of American States/CICAD • Organization of Eastern Caribbean States Secretariat • United Nations Office of Drugs Control and Crime Prevention • The World Bank Group • World Customs Organization

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

Glossary of terms and acronyms

AML/CFT Anti-Money Laundering/Countering the Financing of Terrorism ARIN-CARIB Asset Recovery Inter-Agency Network for the Caribbean BAC Budget and Audit Committee

CARICOM Caribbean Community

CARICOM IMPACS CARICOM Implementing Agency for Crime and Security CARIFORUM Caribbean Forum CDB Caribbean Development Bank CFATF Caribbean Financial Action Task Force CFATF WGFI CFATF Working Group on FATF Issues CICAD Inter-American Drug Abuse Control Commission CIFAD Center for Anti-Drug Training COSUNs Cooperating and Supporting Nations CRTMG CFATF Risks Trends and Methods Group CRWG CFATF Review Working Group CVE Countering Violent Extremism ECCB The Eastern Caribbean Central Bank EDF European Development Fund FATF Financial Action Task Force FATF TREIN FATF Training and Research Institute FIUs Financial Intelligence Units FUR Follow-Up Report FFUR First Follow-Up Report GABAC Groupe d’Action contre le blanchiment d’Argent en Afrique Centrale ICRG International Co-operation Review Group ICS Innovation for Citizen services IFD Institutions for Development

CFATF ANNUAL REPORT 2017-2018 cfatf-ar-2017-2018 March 14, 2019

IMF International Monetary Fund MER Mutual Evaluation Report ML Money Laundering MOU Memorandum of Understanding NAMLC National Anti-Money Laundering Committee NCCT Non-Cooperative Countries and Territories NRA National Risk Assessment OAS Organization of American States PF Proliferation Financing PLC Planning Committee POPR Post-Observation Period Report Scoping Note Document that identifies areas of lower and higher risk that need reduced or increased focus for the onsite visit. Sub-WGFI Sub Working Group on FATF Issues TC Annex Technical Compliance Annex TCI Turks and Caicos Islands TCQ Technical Compliance Questionnaire TF Terrorist Financing WB World Bank